CUNA, NAFCU Speak Out on Risk-Based Pricing Rules

CUNA wants credit unions to have more time to comply with new pricing disclosure rules, and NAFCU wants changes in some of the wording on the disclosure forms.

Those were sentiments expressed in comment letters to the Federal Reserve.

Because of compliance costs, credit unions should have at least an additional six months to comply with requirements to disclose credit scores when letting members know the prices of certain products, CUNA wrote.

The association said the delay was needed because of the many compliance requirements stemming from last year’s regulatory overhaul bill. The regulations are supposed to take effect on July 21.

CUNA Regulatory Counsel Dennis Tsang also wrote that his association hopes that the order of the content on a model notice should not change. and the credit union shouldn’t have to present the credit score information before the credit report information.

He praised the Fed for clarifying in the proposal that a creditor may continue to provide a credit score exception notice instead of a risk-based pricing notice and that creditors won’t have to provide a credit score if it uses information from a credit report that does not include a credit score.

Some of the additional information that financial institutions might be required to disclose in risk-based pricing notices could confuse or mislead consumers, NAFCU wrote in a comment letter to the Federal Reserve.

NAFCU Associate Director of Regulatory Affairs Dillon Shea wrote that statements on the Fed’s model forms, such as "your credit score can change, depending on how your credit history changes" are obvious to most consumers and unnecessarily increase the size of the disclosure.

Shea also wrote that providing the range of the credit score is "of little actual benefit," since the consumer’s score is already required to be on the form.